The Rick Perry TV spot that went on air in Iowa last night and this morning in markets statewide appears to be missing a portion of the required Federal Election Commission disclaimer.

The FEC requires three different boxes to be checked: the candidate's verbal acknowledgment of approval of the message, a written disclaimer saying who paid for it and a written disclaimer on the approval. Perry's ad misses that last piece — text across the screen says, "Paid for by rickperry.org," but it's missing text saying he approved it.

The other issue with that missing piece relates to a Federal Communications Commission ruling involving the ad rates and the mention of a rival candidate, President Barack Obama in this case.

I don't know the rates that the Perry people paid for the ads, but campaigns often try to get the "lowest unit charge," which can be about half the normal rate, and that requires that written disclosure on approval as well. (Our colleague Glenn Thrush did a smart story on this about the Norm Coleman-Al Franken race).

Two election lawyers who are not backing a candidate told me that piece needs to be there. I'm awaiting a Perry response — the ad as it aired in Iowa is below.

UPDATE: Perry communications director Ray Sullivan emails: "Our lawyers approved the disclaimer, but just to be sure we are in total compliance, we're sending an updated version of the spot out today."

UPDATE II: A source familiar with ad buys makes a good point - the FCC issue would not apply here because, among other reasons, it only matters within a 45-day window of the primary or caucuses.